ML20133E966
| ML20133E966 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/29/1985 |
| From: | Hunnicutt D, Kelley D, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133E934 | List: |
| References | |
| 50-445-85-06, 50-445-85-6, NUDOCS 8510100079 | |
| Download: ML20133E966 (9) | |
See also: IR 05000301/2004030
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-445/85-06
Permit: CPPR-126:
Docket:
50-445
Category:
A2
Applicant:
Texas Utilities Electric Company (TVEC)
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES) Unit 1
Inspection At:
Glen Rose, Texas
Inspection Conducted: March 1 - April 30, 1985
Inspectors:
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M/ D. L. Kelley, Senior Resident Reactor
Date
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Inspector (SRRI)
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W. F. Smith, Resident Reactor Inspector
Date
(RRI)
Approved:
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D. M. Hunnicutt, Section Chief,
Ddte /
Reactor Project Section B
Inspection Summary
Inspection Conducted: March 1 - April 30, 1985 (Report 50-445/85-06)
Areas Inspected:
Routine, unannounced inspection of (1) Preoperational Test
Results Evaluation; (2) Independent Inspection Findings; (3) Followup on Open
8510100079 050912
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DETAILS
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Persons Contacted
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Applicant Personnel
- 8. R.L Clements, Vice President, Nuclear Operations
- J. C. Kuykendall, Manager, Nuclear Operations
- C. H. Welch, Site Quality Assurance (QA) Supervisor
- J.' C. Smith, QA
- R. 8. Seidel, Operations Superintendent
- H. A. Lancaster, Startup QA Specialist
- J. M. Ward, Startup QA Specialist
- R. R. Wistrand, Administration Superintendent
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- R. A. Jones, Manager, Plant Operations
- T. Gosdin, Support Services Superintendent
- D. W. Braswell, Engineering Superintendent
- G. D. Smith, Startup Manager
- M. R. Blevins, Maintenance Superintendent
- D. E. Deviney, Operations QA Supervisor
- Denotes those present at exit interview.
- The NRC inspectors also interviewed other applicant employees during this
inspection period.
2.
Preoperational Test Results Evaluation
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The NRC resident inspectors conducted an inspection of preoperational test
data packages which had been completed, approved by the Joint Test Group
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(JTG), and placed in the station permanent records storage facility.
The
objectives of this inspection were to:
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Assure that the appitcant is performing an adequate evaluation of
test results;
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. Assure that all test data are either within previously established
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acceptance criteria, or that deviations are properly dispositioned,
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_ Evaluate the adequacy of the applicant's methods for correcting
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deficiencies and for retesting, if necessary;
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Evaluate the adequacy of the applicant's administrative practices in
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maintaining proper test discipline concerning test execution, test
a'lteration, and test records; and
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Verify that the applicant is following his procedures for review,
evaluation, and acceptance of test results.
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The inspection of each preoperational test package consisted of:
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A review of all test changes to verify that, (1) each change was
approved in accordance with pertinent administrative procedures;
(2) the procedure was annotated to identify test changes; (3) the
test change had been completed if it entailed specific actions; and
(4) none of the changes altered the basic objectives of the test,
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A review of all test deficiencies to verify that, (1) each had been
resolved, that the resolution had been accepted by appropriate
management and the JTG, and that retest requirements had been
completed; (2) any system or process changes necessitated by a test
deficiency were properly documented and reviewed.
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A review of the test summary and evaluation to ensure that, (1) the
System Test Engineer (STE) evaluated the test results and signified
that the testing demonstrated that the system mot design
requirements; (2) the applicant specifically compared test results
with established acceptance criteria.
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A review of the " official test copy" of the test procedure to verify
that, (1) data sheets had been completed (10% minimum sample);
(2) all data were recorded, where required, and were within
acceptance tolerances (10% minimum sample); (3) all test deficiencies
identified were noted and had received appropriate reviews and
evaluations; and (4) individual test steps and data sheets have been
properly signed and dated.
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A review of QA involvement to verify that, (1) QA/QC witness and hold
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points were observed where called for; (2) preoperational test
packages were audited as required by administrative procedures.
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Verification that the test results have been approved by the
applicant's JTG and that the review and approval is documented as
required by administrative procedures,
a.
The following completed preoperational test data packages were
reviewed by the NRC inspectors, with no comments, and have met the
inspection attributes listed above:
(1) ICP-PT-64-02, " Reactor Protection System," Revision 0.
(2) ICp-PT-64-02, RT-1, " Reactor Protection System - Retest 1,"
Revision 0.
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f(3) .,1CP-PT-64-02, RT-2, " Reactor Protection System - Retest 2,'.'.
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~ Revision O.
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(4) ICP-PT-64-04, " Reactor Plant System Setpoint Verification,"
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Revision 0.
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1(5) '1CP-PT-37-01, " Auxiliary Feedwater System (Motor Driven),"
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Revision 0.
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(6) ICP-PT-37-01[ RT-1, " Auxiliary Feed Water System (Motor Driven)
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Retest-1," Revision 0.
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(7) ICP-PT-37-03, " Auxiliary Feedwater Turbine Driven Pump,"
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Revision O.
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(8) .ICP-PT-37-03, Redo, " Auxiliary Feedwater Turbine Driven Pump
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Redo," Revision O.
.(9) ICP-PT-02-12, RT 1, " Bus Voltage and Load Survey, Retest-1,"
Revision 0 (phase I & II).
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The following completed preoperational test data packages were
reviewed by the NRC resident inspectors, and have met the inspection
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attributes listed above, except as described in the following
comments:
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(1) ICP-PT-34-01, " Main Steam Isolation Valves" (MSIV), Revision 1.
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The NRC inspector noted that only MSIV control circuit
operability had been successfully tested by this procedure.
The
procedure was originally intended for operationally testing the
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valves as well as the control circuits; however, due to
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extensive failures and repairs, it was necessary to defer the
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testing of the MSIVs and MSIV bypasses (MSIVBV) from the
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preoperational test program to the initial startup (ISU) program.
During a second hot functional test sequence' conducted in
November and December 1984, the MSIVs were successfully tested
in accordance with ISU-234A, " Main Steam Isolation Valves
Operability and Response Times. The MSIV8Vs continued to have
problems with the electro-hydraulic valve operator, resulting in
a decision to place manual operators on the MSIVBVs and to
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implement the appropriate procedure changes what will be
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necessary to support manually operated MSIV8Vs.
Final NRC
acceptance of this test will be contingent upon a satisfactory
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review of the completed Initial Startup Test package for
ISU-234A. 'This package will be inspected under the startup
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testing phase of the NRC light water reactor inspection program
(Inspection and Enforcement Manual Chapter 2514).
This is an
Open Item 445/8506-01.
(2) 1CP-PT-64-01, "RPS Time Response Measurement," Revision 2.
Test Deficiency Report (TDR) 3799 was filed in the completed
test package with no corrective action-specified and no evidence
that it had been closed.
The TDR was not addressed in the test
summary as an open TDR.
The subject was opening times of.
containment spray valves 1-HV-4776 and 1-HV-4777.
It appeared
that the valves were designed to open in less than 20 seconds.
The containment spray system design assumes it will be more than
117' seconds to preclude pump run-out. According to the
applicant's representatives, this problem was discovered during
the analysis of ICP-PT-64-01 data, but had no bearing on the
outcome of the test because the time responses of ICP-PT-64-01
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do not include actual valve operating time.
The practice of
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having an open TDR in a completed test data package without a
JTG approved disposition does not meet the NRC inspection
criteria above.
This is Open Item 445/8506-02.
Test Procedure Deviation (TPD) No. 18 changed two prerequisites
from lifting of leads to jumpering of contacts to prevent valve
1-HV-4168 from cycling during the test because p set of contacts
in the control circuit needed to remain closed (simulated by
jumper) rather than remain open (which would be simulated by
lifting leads).
The " Reason for change" indicated, " Change ~
prerequisite to prevent cycling of value 1-HV-4168," instead of
indicating why, which was to correct a procedure error.
In NRC
Inspection Report 50-445/85-02, the RRI commented that
inaccurately stated reasons for changes is a widespread problem.
This is another example.
The applicant's action to correct this
_ roblem is already being tracked under Open Item 445/8502-02.
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No' violations or deviations were identified.
'As of this inspection the.preoperational testing phase of the NRC
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' Light Water Reactor Inspection Program, Inspection and Enforcement
- Manual Chapter.2513 is completed, with exception of any retests that
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dispositioning previous preoperational test inspection findings.
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Independent '-Inspection Findings
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" Deficiency Report Review
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The~RRI'selec'ted,'at random, an operations Deficiency Report (DR) to
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verify that appropriate corrective actions were being taken by TUGC0
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_ operations management.
The DR selected was DR 85-012, which pertained
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to replacement ~of a failed shaft seal on No. 2 Reactor Coolant (RC)
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pump in accordance with Maintenance Action Request (MAR) 85-0292,
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which in turn implemented Mechanical Maintenance Instruction (MMI)
302, " Reactor Coolant Pump Seal Inspection."
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Revision l'of MAR-85-0292 stated, " Steps of this procedure (MMI-302)
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'may be worked out of sequence as long as the integrity of the job is
not affected;" According to the DR, the mechanics performed MMI-302,
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steps 5.2.7.11 before 5.2.7.9, and 5.2.7.8 after 5.2.7.9.
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resulted in damage to the lower seals, and particles from the broken
seal dropping into the upper RC pump housing.
.The recov'ery actions as documented on the DR appeared to be
. inadequate for the circumstances.
Under " Corrective Action" the
Maintenance Engineer simply stated that the No. 1 lower seal ring
will'be replaced in accordance with MMI-302, paragraph 5.4.2.
Under
" Preventive Action" the same engineer indicated, " Applicable
-maintenance personnel will be instructed'in the importance of working
instructions in sequence.
This review will be documented in
accordance with MDA-106." The RRI noted the following specific
problems with this-scenario and the associated documentation:
(1) ' MAR-85-0292 was chacged to allow deviations-from MMI-302 with-
out an approved cha ge as required by Section 4.5.3 of MDA-201.
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One of the caus_es o' the deficiency was failure of the people
who approved-the change to recognize this.
The disposition
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entered on'DR.85-012 failed to address corrective actions to
prevent recurrences of such improper reviews, which is in
violation.of J4ction 4.7 of STA-404, " Control of Deficiencies."
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(2) -DR 85-012 was initiated on 1/24/85, _The QC inspector on the job'
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verified cleanness of the RC pump oanulus using fibre optics on
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January 31, 1985. There was no documentation-showing what
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Failure to provide such a procedures is contrary to the require
-ments of 10 CFR 50, Appendix B, Criterion V, and Section 13.1
of the applicant's Operations Administrative Control and Quality
Assurance Plan.
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(3) Maintenance Department Administrative Procedure MDA-201,
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'" Electrical and Mechanical Maintenance Procedures and
Instructions," prescribes the formatting and revision control of
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instructions ~such as MMI-302.
Step 4.3.7.3 of MDA-201 appears
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to leave it at the option of procedure writer to number the
steps and the exact sequence of performing the maintenance, and
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that if the exact sequence is,not essential, the writer has the
option to so state.
On the other hand, step 4.5.3 requires a
change to the procedure if the sequence of steps within a section
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or subsection must be changed.
When the NRC inspector began to
probe the details associated with DR 85-012, the applicant
recognized this problem and documented it on DR 85-078.
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(4); The NRC' inspector noted that DR_85-012 was reviewed by
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MaintenanceiDepartment Personnel in accordance with MDA-106,
" Document-Review." One objective of_this procedure is to
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may learn from.the experience ~of others. The DR was only
disseminated to the two mechanics'who experienced the problem in
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'the'first place.' ,
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In summary, dodumentation m'ade availabl~e to the NRC inspector
indicates a failureion the part'of the applicant to provide and or
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follow procedures'in accordance with.10'CFR'Part 50, Appendix B,.
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.Criterioh'V, and Section113.1_of-the Operations Administrative
Control Plan. ~The Operations QA Program" failed to' ensure the
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' adequacy of corre~ctive' actions ~ . The dissemination of lessons
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learned'to the" appropriate' personnel is considered an open item.
- This is Open Item 445/8506-04.
Thisis(0 pen) violation:445/85b6-0'3.
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Fuel Storage-Inspect' ion / Fuel Inventory
- During this reporting period-th'e NRC inspectors performed an
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-inspection of the fuel storage facilities and an inventory of the
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' Unit 1, Cycle 1 fuel and associated fuel bundle inserts.
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The! storage facility inspection consisted of:
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Verification of security:and access control,
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Verification of the cleanliness of the area,
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Verification of the cleanliness of'each fuel element and storage
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cell and,
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Verification of the radiological controls.
The fuel inventory consisted of:
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Verification that each fuel assembly and insert were accounted
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Verification that each fuel assembly and its insert were in
their assigned storage cell and,
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Verification that each assembly and its insert, when moved from
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one' location to another, were logged.on a transfer sheet.
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-The fuel storage areas (both the new fuel storage and spent fuel
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- storage)-were. examined by the NRC inspectors.- The areas were found
. to 'be clean 'an'd free of foreign material, required' radiological
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controls were-in effect, and the-required security provisions were
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implemented.
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The NRC. inspectors al'so performed an inventory of all Unit 1, Cycle.1'
nuclear fuel and fuel element inserts. The inventory was performed
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map was used.to record the contents of each storage cell in the new
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fuel and spent fuel storage area). . The filled in. maps were then
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compared to the applicant's records identifying the assigned storage-
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. cell-' and . its contents ~.
In addition, for each fuel movement since
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receipt.,the fuel transfer documents were examined.
The inspectors
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found that each fuel element and its insert was in its assigned.
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Clocation and each fuel assembly movement was recorded on the required
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transfer documents.
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'No ; violations or deviations were . identified.
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. Followup on Open Items-
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..TMI Action Plan Item
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- Item II.E.1.1: required verification by. test, that the turbine driven
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auxiliary feed pump could operate a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />'without AC power.
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cDuring t'he performance of ICP-PT-37-03, Revision 0, " Auxiliary Feedwater
~ Turbine Driven Pump", the pump was run for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with.no AC power, as
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part.of.the 48-hour run. -During this 2-hour run there was no ventilation
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to the room and the ventilation dampers were shut._ Thetemperatgreand
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. humidity requirements of the ~2-hour portion of the gest were 104 F ~and
70%.
The final temperature and humidity were 107.7 F and 100% humidity.'
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Gibbs and Hill' analyzed the deviation and concluded in GTN-65740 to use
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as is.
Since the conditions were more severe than-the test criteria, the'
. -intent of the test was not lessened.
The NRC. inspector concludes that the
2-hour' test has met the: requirements of Item II.E.1.1.
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Thisiitem is closed.
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5.
Plant Tours
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During this reporting period, the.SRRI and RRI conducted several
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inspection tours of. Unit 1.
In addition to the general housekeeping
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. activities 1and general cleanliness of the facility, specific attention was
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ogiven.to. areas where' safety-related equipment was instslied and where
activities ~were in' progress involving safety-related equipment. These
areas were-inspected to ensure that:
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Work in progress was being accomplished using approved procedures,
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Special precautions for protection of equipment were implemented, and
-additional ~ cleanliness,' requirements were being adhered to for
maintenance,' flushing, and welding activities.
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Installed safety-related equipment and components were being-
protected and maintained to prevent damage and deterioration.
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iAlio during these' tours,,the SRRItand RRI. reviewed the control room and'
? shift: supervisors' log book.' Key items in.the log review were:
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plant status
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changes in-plant ~ status.
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' tests in. progress.
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documentation.of problems which arise during operating shifts
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No deviations or violations were identified.
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Plant Status.as of April-~30,21985
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Unit 1Lis 99% complete'with 323 of 332 subsystems turned over to
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operations custody.
Custody" means having immediate authority and
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- responsibility for operational control of system or equipment.
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.The applicant has. accepted:305 of 332 subsystems for final
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Of _ the 199 preoperational tests, one is ;not yet completed on field
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itesting,~and.27 are pending review and approval of completed data.
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- There are no.further tests requiring NRC results evaluation review.
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The'following; items related to NRC' resident operations office
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' ~ i.9_ findings are open pending applicant action and NRC followup
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inspection to confirm. completion for closure:
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. Violations
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. Deviations
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- _Open. Items
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.Unresolve'd
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Closure will'be
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documented'in future inspection reports.
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Unit.'2 is 73% complete. The.preoperationalitest. program on systems-
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associated with NRC inspections.has not yet, started.
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. Exit-Meeting
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An~ exit interview was conducted May 2, 1985, with applicant
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representatives identified in paragraph 1.
During this interview, the
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ESRRIm reviewed the scope and discussed the inspection findings.
The
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_ applicant acknowledged the-findings.
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